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Strategic TSCA Legislative and Regulatory Counsel

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 With over 15 years of legal and policy experience in the chemical, oil, and gas sectors, we provide high-level strategic counsel to help companies navigate complex federal frameworks, defend manufacturing capabilities, and advance enterprise sustainability goals.

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UPCOMING TSCA LEGISLATION 

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Having actively lobbied and provided strategic advocacy during the drafting and passage of the 2016 Frank R. Lautenberg Chemical Safety for the 21st Century Act, Kennedy Law and Policy offers a distinct advantage rooted in a profound understanding of the law's original legislative intent. Throughout the TSCA modernization process, we spearheaded industry coalitions, uniting diverse chemical manufacturers, energy companies, and trade associations to present a cohesive, persuasive voice to lawmakers. By directly representing these enterprises in high-stakes policy negotiations, we successfully shaped core statutory provisions to ensure the new framework balanced rigorous safety standards with supply chain viability and industrial innovation.

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Today, this foundational, on-the-ground legislative experience allows us to aggressively defend our clients against regulatory overreach. We don't just interpret current EPA rules—we leverage the statute's foundational intent to build administrative records that protect your license to operate.

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When the regulatory environment shifts, businesses need an advocate who understands the intersection of administrative law, supply chain realities, and complex chemistry. We bridge the gap between technical reality and political possibility...and we have the accomplishments to prove it. 

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 Navigating the EPA's aggressive implementation of TSCA requires more than standard compliance—it demands proactive, technically sound advocacy. We protect your enterprise's license to operate across the full spectrum of chemical regulation, including:

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  • Navigating complex Section 8(a)(7) PFAS reporting and supply chain auditing.

  • Securing critical-use exemptions under Section 6 Risk Management rules for high-priority substances.

  • Accelerating the New Chemical Review process (PMNs and SNUNs) to bring sustainable innovations to market.

  • Ensuring compliance with international frameworks, including REACH and Globalized Harmonization Systems (GHS).

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Federal Rulemaking & Administrative Law Effective advocacy requires building an administrative record that can withstand scrutiny and litigation. Having drafted and submitted over 20 formal rulemakings to the EPA and other federal agencies, Kennedy Law and Policy possesses the deep Administrative Procedure Act (APA) expertise necessary to challenge flawed baseline agency assumptions. We routinely lead coalition efforts, build consensus among diverse stakeholders, and translate complex engineering data into persuasive legal arguments.

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Circularity & The Energy Transition As global environmental frameworks evolve, so do the opportunities for industry innovation. We lead enterprise-wide strategies influencing both federal and intergovernmental policy on advanced recycling, renewable fuels, and the circular economy. Whether engaging with the Department of Energy (DOE) on infrastructure or navigating the implications of the UN Plastics Treaty, we ensure your business is positioned to lead in the clean energy transition.

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If the EPA’s risk evaluations or significant new use rules (SNURs) exceed their statutory authority, we know exactly how to build an administrative record to challenge them.

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Featured Regulatory Comments & Advocacy
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Below is a selection of the 20+ formal rulemakings and technical comments Kennedy Law and Policy has drafted and submitted to the EPA, representing major trade associations and industry coalitions to protect manufacturing capabilities and supply chain viability:

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  • TSCA Section 8(a)(7) & New Chemical Reviews (SNURs) for PFAS

    • Focus: Challenged the EPA’s unprecedented expansion of Significant New Use Rules (SNURs) for PFAS and precursor chemicals. Submitted comprehensive comments opposing the Agency's attempt to circumvent statutory review periods and pushed back against unworkable supply chain reporting requirements that ignored the "known or reasonably ascertainable" standard.

    • Federal Record Link: View Formal Comment on SNURs and Precursor Chemicals (Docket EPA-HQ-OPPT-2023-0245)

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  • Risk Management for Trichloroethylene (TCE) under TSCA Section 6

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  • Risk Evaluation and Management for Chrysotile Asbestos (TSCA Section 6)

    • Focus: Advocated for the protection of safe, highly regulated industrial uses of asbestos within the oil, gas, and chlor-alkali sectors. Formally challenged the EPA's flawed systematic review protocol and "whole chemical" approach, arguing that the Agency failed to appropriately segregate complex petroleum process streams and existing workplace safety frameworks from their baseline risk determinations.

    • Federal Record Link: View the Federal Register Notice for Asbestos Risk Evaluation (Docket EPA-HQ-OPPT-2021-0254)

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  • Updates to New Chemicals Regulations (PMN and SNUN Processes)

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  • 1,4-Dioxane Draft Supplement to Risk Evaluation

    • Focus: Formally engaged the EPA regarding the introduction of novel methodologies for hydraulic fracturing exposure scenarios, successfully advocating for industry's right to thoroughly analyze practical implications.

    • Federal Record Link: View Request on 1,4-Dioxane (Docket EPA-HQ-OPPT-2022-0905)

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  • Risk Management for Carbon Tetrachloride (CTC)

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